VIOLATIONS OF NPDES PERMITS ISSUED TO THE TOWNSHIP FOR THE DISCHARGES FROM THE TWO TREATMENT PLANTS INCLUDE EFFLUENT LIMITATIONS VIOLATIONS, FAILURES TO COMPLY WITH SCHEDULES OF CONSTRUCTION ACTIVITIES, AND FAILURES TO OPERATE AND MAINTAIN THE PLANTS PROPERLY. INJUNCTIVE RELIEF SOUGHT THAT IMPOSES AN EXPEDITIOUS CONSTRUCTION SCHEDULE, INTERIM OPERATION AND MAINTENANCE IMPROVEMENTS, INTERIM EFFLUENT LIMITATIONS, AND A SEWER BAN. OUR ONLY RECENT CONTACTS WITH THE DEFENDANT WERE A SERIES OF PLANT INSPECTIONS REVEALING OPERATION AND MAINTENANCE DEFICIENCIES. COMPLIANCE WITH THE REQUIREMENTS AND GOALS OF THE NATIONAL MUNICIPAL POLICY ARE THE SIGNIFICANT NATIONAL OR PRECEDENTIAL LEGAL OR FACTUAL ISSUES. WE ALSO SEEK A SUBSTANTIAL CIVIL PENALTY FOR PAST VIOLATIONS OF THE ACT AND THE PERMITS. THE PROPOSED PENALTY IS CONSISTENT WITH THE CLEAN WATER ACT CIVIL PENALTY POLICY. WHILE WE WILL SEEK A HIGHER PENALTY, OUR BOTTOM-LINE SETTLEMENT FIGURE IS $42,000.